The Impossibility of ‘Legal Transplants’

[A] comparative study [shjould not aim at finding ‘analogies’ and ‘parallels’, as is done by those engrossed in the currently fashionable enterprise of constructing general schemes of development. The aim should, rather, be precisely the opposite: to identify and define the individuality of each development, the characteristics which made the one conclude in a manner so different from that of the other. This done, one can then determine the causes which led to these differences. Max Weber1